Notice_of_motion_and_motion_to_determine_venueMotionCal. Super. - 5th Dist.April 6, 2020Th is e - c o p y is th e of fi ci al co ur t re co rd ( G C 6 8 1 5 0 ) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DANIEL J. OGDEN, SBN 276434 TYLER A. KELLY, SBN 28807 KELSEY L. KERN, SBN 298657 ‘OGDEN Law FIRM, PC = ATTORNEYS AT LAW 1535 J Street, Suite A Modesto, CA 95354 Tel: (209) 524-4466 Fax: (209) 524-1660 Attorney for Respondent, Yollanda Griddine SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF MERCED DIANA HANNA, an individual, AND TIMOTHY MURPHY, an individual, Together as Plaintiffs, V. YOLLANDA GRIDDINE, individually and as trustee of the MURPHY FAMILY TRUST DATED OCTOBER 28, 1999, AND DOES 1-100, together as Defendants TO ALL PARTIES AND THEIR ATTORNEYS: NOTICE IS HEREBY GIVEN that on July 21, 2020 at 8:15 a.m., or as soon thereafter ag the matter may be heard, in Department 8 in the above-entitled Court, which is located at 627 West 21% Street, Merced, California, 95340, Respondent YOLANDA GRIDDINE (“Plaintiff”) will move for an order changing venue to the Superior Court of California for the County of Contra ELECTRONICALLY FILED Merced Superior Court 6/17/2020 8:32 AM Amanda Toste Clerk of the Superior Court By: Kristifer Hew, Deputy Case No.: 20CV-01606 NOTICE OF MOTION AND MOTION TO DETERMINE VENUE Date: July 21, 2020 Dept.: 8 Time: 8:15 a.m. NOTICE OF MOTION AND MOTION TO DETERMINE VENUE Th is e- co py is th e of fi ci al co ur t re co rd ( G C 6 8 1 5 0 ) No County of Contra Costa. Plaintiff brings this motion pursuant to California Code of Civil Procedure Sections 396b and 397(a). This motion to change venue is based on this notice of motion and motion to change venue, the memorandum of points and authorizes filed herewith, the declaration of Kelsey L. Kern, all pleadings and records already on file in this action, all matters of which judicial notice may bgj taken, and such further oral and documentary evidence as may be presented at hearing of the motion. OGDEN LAW FIRM, PC Dated: Pane le, LAP Rd ry . KERN el r Respondent NOTICE OF MOTION AND MOTION TO DETERMINE VENUE 2 Th is e- co py is th e of fi ci al co ur t re co rd ( G C 6 8 1 5 0 ) 14 15 16 PROOF OF SERVICE [CCP §1013a(3)] I, the undersigned hereby declare: I am a resident of Stanislaus County, California; I am over the age of 18 years and not a party to the within action; my business address is 1535 J Street, Suite A, Modesto, Stanislaus County, California. I am familiar with this firm's practice for collection and processing of correspondence for mailing. Under that practice it would be deposited with U.S. Postal service on that same day with postage thereon fully prepaid at Modesto, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. On June V1, 2020, I served the foregoing document described as NOTICE OF MOTION AND MOTION TO DETERMINE VENUE on the parties in this action by placing a true copy thereon enclosed in a sealed envelope and with postage thereon fully prepaid, for collection and deposit to the U.S. Postal Service addressed as follows: Brenda Scott 1765 Delta Meadows Way Oakley, CA 94561-3140 Diana Hanna 2910 Fisher Glade San Antonio, TX 78245 Timothy Murphy 2321 Peach Tree Drive Fairfield, CA 94533 Danielle Garcia CDCR WF8787 Central California Women’s Facility P.O. Box 1508 Chowchilla, CA 93610 NOTICE OF MOTION AND MOTION TO DETERMINE VENUE 1 Th is e- co py is th e of fi ci al co ur t re co rd ( G C 6 8 1 5 0 ) 12 13 14 15 18 19 20 Sydney Murphy 8500 20" Avenue Seattle, WA 98115 Thurman J. Murphy, III 4933 Country Breeze Court N. Las Vegas, NV 89031 Dorothy Murphy 7945 Turtle Island Court Las Vegas, NV 89129 Yollanda Griddine 1216 North Towne Drive Altus, OK 73521 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. Executed on: June\7, 2020 lose. ork Nikki Blewett NOTICE OF MOTION AND MOTION TO DETERMINE VENUE 2
